Processing document β€” OCR in progress…
May take a minute for large PDFs.
Records: 897 EMPLOYER 1 WORKSAFE 5 LEGAL 8 INTERNAL 852 PERSONAL 31 ⭐ Key: 26 | Last import: 2026-05-11 10:20
← HOLAND_CLAIM_FILE_p011WCB REBUTTAL … HOLAND_CLAIM_FILE_p011WCB REBUTTAL … β†’
WCB REBUTTAL CLINICAL OPINION PANG MAR20 06
πŸ“„ HOLAND_CLAIM_FILE_p008 to p015 | p.13
πŸ“ Extracted Text (OCR)
| work Fale BC Memo

WORKING TO MAKE A DIFFERENCE (continued)

Worker last name First name Middle initial WorkSafeBC claim number
HOLAND MARK 42647461

Flora Pang referenced my photographs and simultaneously described the source as
computer fans. Anyone reviewing the photographs and the clinical opinion
simultaneously will observe this contradiction immediately.

This contradiction exists within the clinical opinion's own cited evidence.

ERROR 11 β€” MIGRAINE HISTORY MINED AND MISREPRESENTED

The clinical opinion places significant weight on the worker's long history of
migraines as evidence that his condition is pre-existing and non-occupational.

This characterization misrepresents the nature of my migraine management.

A long history of migraines managed through regular medical check-ins every three
to four months for prescription renewal and trigger management does not constitute
a debilitating pre-existing condition. | have been actively working to reduce migraine
frequency by identifying and eliminating triggers. My migraines were successfully
managed prior to January 12, 2026.

The critical clinical fact that the clinical opinion does not address is this β€” my first
ever Emergency Room visit for a migraine was January 30, 2026. Not before. Every
prior medical contact regarding migraines was routine outpatient management.
Standard prescription renewal. Trigger discussion. Supplement review.

A worker who has never required emergency care for migraines in his entire life and
then attends the Emergency Room for the first time on January 30, 2026 β€” 18 days
after beginning exposure at Workstation 3 β€” is not presenting a pre-existing
condition running its normal course. He is presenting a pre-existing condition that
has been catastrophically destabilized by a new workplace exposure.

That distinction is clinically significant and entirely absent from this opinion.

ERROR 12 β€” DR. ZAHABI'S OBSERVATION INVERTED

The clinical opinion cites Dr. Zahabi's suspicion that the work environment might
have triggered the worker's migraine headaches and then uses this observation to
support a conclusion of non-occupational causation.

This is the direct opposite of what Dr. Zahabi's observation supports.

Dr. Zahabi suspected workplace triggering. That is a medical professional
identifying potential occupational causation. Under WorkSafeBC's aggravation
principle a workplace exposure that triggers or aggravates a pre-existing condition
is compensable.

Furthermore Dr. Zahabi's observation was the clinical turning point that led me to
understand my condition was sensory in nature β€” acoustic stimuli triggering a
physiological cascade. His observation was not evidence against my claim. It was
the first medical professional acknowledgment of the mechanism | had been
describing since January 2026.

Flora Pang inverted the clinical meaning of Dr. Zahabi's observation to support
denial of a claim for the exact condition Dr. Zahabi suspected.

ERROR 13 β€” NOISE SENSITIVITY HISTORY MISREPRESENTED

The clinical opinion states the worker noted that he has a history of sensitivity to low
level noises.

This is a material misrepresentation of what | reported.

| stated | have high fidelity hearing. | have protected my hearing throughout a 30
year career in heavy industry precisely because | value it as my most important

68B33 (RO1/09) Page 6 of 9